ML20004D317

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Responds to NRC Re Violations Noted in IE Insp Rept 50-395/81-05.Corrective Actions:Sys Retested in Accordance W/Code Hydro Test CS-21-H1
ML20004D317
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 05/13/1981
From: Nichols T
SOUTH CAROLINA ELECTRIC & GAS CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20004D316 List:
References
NUDOCS 8106090157
Download: ML20004D317 (3)


Text

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.o SOUTH CAROLINA ELECTRIC a gas COMPANY f

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v ColumsiA Soures CAnouNA 29218 T. C. NicHo Ls, J a.

May 13, 1981 v,c,............o m c m o,~,

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Mr. James P. O'Reilly, Director U.S. Nuclear Regulatory Commission Region II, Suite 3100 101 Marietta Street, N.W.

Atlanta, Georgia 30303

Subject:

Virgil C. Summer Nuclear Station Dockee No. 50/395 RII:

JLS-50-395/81-05

Dear Mr. O'Reilly:

Attached is South Carolina Electric and Gas Company's response to the referenced report which summarizes Mr. J.L. Skold's inspection of February 12.

1981 through March 31, 1981.

Specifica1ly, we have addressed the violations concerning verification of hydrostatic test boundaries and subsequent approva of unacceptable test results.

Should you have questions or comments, please contact us at your convenience.

I declare the statements and matters set forth herein are true and correct tc the best of my knowledge, information and belief.

W f./.ou T.C. Nichols, Jr.

JWP:TCN:bsg ATTACHMENT cc:

V.C.

Summer J.L. Skolds G.H. Fischer B.A. Bursey T.C. Nichols, Jr.

Dr. J.C. Ruoff 0.W. Dixon, Jr.

0.S. Bradham C.A. Price H. Radin D./..

Nauman Document Management Branch W.A. Williams, Jr.

(55e/21/LER Cnly)

R.B. Clary ISEG A.R. Koon NPCF A.A. Smith PRS H.N. Cyrus File J.B. Knotts, Jr.

28.10 6 0 90/$/

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Page 1 of 2 i

i SOUTH CAROLINA ELECTRIC & CAS CO.

VIRGIL C. SUMMER NUCLEAR STATION, UNIT #1 1

I DOCKET NO:

50-395 I

l REPORT NO: RII:JLS 81-05 f

NOTICE OF VIOLATION l

EVENT DATE: JANUARY 27, 1981 i

I i

f DESCRIPTION OF EVENT f

f 1

10 CFR 50 Appendix B, Criterion V, as implemented by FSAR Section 17.1.5 of the FSAR requires that activities affecting quality be prescribed by docu-mented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Quality Control Procedure VII-13, " Quality i

Verification of Hydrostatic and Pneumatic Tests", Section 4.6.6 requires that all valves within the test boundary be properly aligned so that all components will be subjected to test pressure.

l Contrary to the above, on January 27, 1981, Hydrostatic Test CS-21-H1, Holdup i

~

j Tank,.was performed and subsequently approved with valve 8620 shut, preventing the piping between valve 8620 and 8621 (Hydrostatic Test Boundary) from being subjected to test pressure.

l l

f ADMISSION OR DENIAL OF ALLEGED VIOLATIONS i

South Carolina Electric and Gas Company recognizes this item as a violation of the aforementioned regulatory requirements.

i f

REASONS FOR VIOLATION

[

l The section of pipe between valves 8620 and 8621 was omitted from subjection

[

to the hydrostatic test pressure of test CS-21-H1 due to an over-sight by a j

quality control (QC) inspector and a procedure deficiency.

j t

The QC inspector failed to accurately " Verify that all valves within the test boundary are properly aligned so that all components will be subject to the i

test pressure" as specified in procedure QCP VII-13, " Inspection of Hydrostatic l

+

and Pneumatic Testing". The physical configuration of the subject valves l

contributed significantly to the cause of this over-sight. The valves, number; j

8620 and 8621 are in series and~not more than two (2) inches apart with the j

check valve 8621 being the test boundary valve.

The inspector, being accustomeu to verifying that boundary valves are in the " closed" position, inadvertently l

j verified that the incorrect valve, diaphram valve 8620, was " closed".

[

i j

During pretest updating of procedure CS-21-H1, "CVCS Hold-Up Tank Header Hydr,'

f the required test position of diaphram valve 8620 was changed from "open" to

" closed" in error.

This error was not detected during review of test results.

CORRECTIVE STEFS TAKEN I

Prior to performance of test CS-21-H1, the omitted section had been hydro-testec l

to the pressure called for in CS-21-H1 under the auspices of non-code hydro CS-25-H1.

This action verified the integrity of the omitted section and the l

error, had it gone undetected, would not have adversely effected the safety of j

i j

.---_-,,,,-.__,-,-._,-,_..--.,nn,,

1-e NOTICE OF VIOLATION Page 2 CORRECTIVE STEPS TAKEN (cont'd.)

operations of the V.C. Summer Nuclear Station.

However, further verifica-tion of systen integrity has been achieved through re-test of the system in accordance with code hydro test CS-21-Hl.

CORRECTIVE STEPS TAKEN TO PRECLUDE RECURRENCE A one-hundred percent (100%) review program of safety-related piping hydro-static test results has been implemented per administrative directive con-tained in letter SER-543-SU.

This program will assure that no other errors in procedure preparation and/or conduct of hydrostatic tests go undetected in the startup program.

The possible safety implications of this type incident has been discussed with Quality Inspectors.

The inspectors were also requested to place special emphasis on the position of all boundary valves in checking pressu-rization of hydro tests.

DATE OF FULL COMPLIANCE The actions stated above shall be effected by June 1, 1981.